Sandeel fishing - proposed closure: consultation analysis

Section C: Any further evidence that should be considered (Q3)

Response to the consultation

Question 3 of the consultation asked respondents for any further evidence that they thought should be considered in terms of the potential benefits or value of the preferred option. A total of 173 respondents gave responses to this question, with 129 coming from individuals and 44 from organisations (see Table 5).

Sandeel population important for the protection of other species

As mentioned earlier, the vast majority of respondents emphasised the value of increased sandeel populations – which could come from the preferred option to close fishing for sandeel throughout all Scottish waters – in the protection of other species.

A need to protect seabirds – particularly those in decline - was widely cited. Many mentioned the significance of sandeel for kittiwake and puffin populations, where sandeel are a vital food source and thus contribute to improved lifespans and breeding success amongst these birds. Others went on to discuss the wider benefits of seabird communities to ecosystems, where they, for instance, account for large amounts of nutrient turnover.

There was a general sentiment that a resulting increase in sandeel populations would help seabird colonies become more resilient and ‘give them a chance’ against the pressures of avian flu and other plights:

“Seabirds are one of the most threatened groups of birds in the world and Scottish seabirds rely heavily on sandeels as their main food source. Closing sandeel fisheries would greatly reduce some of the pressures facing these incredible species” – [Individual].

In addition, sandeel were highlighted as a critical source of food for other fish, like salmon, sea trout and mackerel. Many respondents saw sandeel as playing a core role in the marine food web and felt the closure of fishing for sandeel throughout all Scottish waters would boost the health and abundance of other marine species. Consideration was also given to the benefits for larger marine mammals, like whales and dolphins:

“Numerous marine mammals and sea birds consume Sandeels in this part of the region, especially minke whales. It has been showed that the movements and seasonal patterns of minke whales can be mapped to match that of sandeel habitats. Marine mammals are vulnerable and face several other anthropogenic threats which cannot easily be controlled in one area (sea temperatures rising for example) but the closure of sandeel fisheries would be invaluable for the species who are resident and seasonal” – [Individual].

Wider benefits for biodiversity, wellbeing, rural tourism and sustainability

Many respondents disseminated the wider benefits of the preferred option – i.e. the closure of fishing for sandeel throughout all Scottish waters – on biodiversity, wellbeing, rural tourism and economic and environmental sustainability.

They commented that the closure of fishing for sandeel in all Scottish waters would help ensure the future health of biodiversity and the planet and emphasised a need for such care in the context of the climate crisis. More specific benefits of the closure on river and sea-bed health, water quality and increased carbon capture were also mentioned:

"The wider benefits to the marine environment of increased biomass of sandeel, such as the increased carbon capture potential of an ecosystem with more biomass" – [Individual].

Others saw the subsequent boost to the health and numbers of other species (as a result of the preferred option) as advantageous in improving public wellbeing. Respondents linked the presence of healthy wildlife populations with opportunities for people to feel connected to nature and take part in activities like bird/wildlife watching. Such opportunities were seen to benefit local residents and communities and encourage rural tourism, for instance, through the wider revenue brought by visitors to areas with large puffin colonies.

Some respondents discussed the impact of the preferred option in sustaining the rural economy across Scotland, particularly where so-called ‘iconic’ Scottish fish – like Atlantic salmon – are important to the packaging/manufacturing and food and drink sectors.

Positives linked to the cessation of vessels targeting sandeel

Several respondents highlighted the perceived positive impact of the cessation of vessels targeting sandeel. Some gave an example of the impact of a Marine Protected Area (MPA) in the Western Isles, leading to additional white fish stocks, while others felt that having fewer sandeel-targeting vessels and related fishing gear would limit disruption to seabeds:

“Industrial trawling for sandeels has negatively impacted their abundance causing a decrease in stock size which makes them less resilient to interannual variability and changes in environmental conditions. […] Other forms of commercial fishing also have an impact on sandeels but to a lesser extent. For example, there is evidence for a decrease in sandeel abundance in areas that sustain a high intensity of bottom towed fishing” – [Organisation].

Other Commentary

Others commented on the proportion of current sandeel catch by EU’s Scandinavian, namely Danish, vessels for fishmeal, as well as for pig and mink feed. Some felt this is unnecessary where sustainable alternatives for high protein animal feed are becoming available. In addition to this, others believed that bycatch is ‘unchecked’ and that Danish fleets’ access to Scottish waters should be revoked.

Indeed, some noted that EU countries have been allocated around 97% of the Total Allowable Catch (TAC) for sandeel in UK waters for 2023, while sandeel has not been fished commercially by a UK vessel since 2021.

Some respondents noted the importance of co-ordination between English and Scottish legislation – if England proceeds with the closure of fishing for sandeel but Scotland does not – with concerns there could be displacement to Scotland’s waters. A summary of responses to the UK government consultation was published in July 2023.^[17]

Several respondents raised concerns about the threats that offshore wind developments pose to seabirds like kittiwakes or puffins, by forcing them to travel further to find food or causing collisions with turbine blades. It was felt, then, that the closure of fishing for sandeel throughout all Scottish waters might be beneficial in driving seabirds away from these dangerous areas, as they look for food elsewhere. Some suggested that making the benefits of a closure of fishing for sandeel in Scottish waters available as a compensation measure for offshore wind farm projects (or any other developments) would help to realise the Scottish Government’s Net Zero targets.

Conversely, a small number of respondents floated the possibility of an allowance for catching small, specific quantities of sandeel as part of recreational fishing.

One respondent who did not support the introduction of the preferred option said they were unconvinced of its scientific rationale and feel that more needs to be done to quantify any resulting displacement.